UNITED STATES DEPARTMENT OF COMMERCE National Oceanic and Atmospheric Administration NATIONAL MARINE FISHERIES SERVICE Southwest Region 501 West Ocean Boulevard , Suite 4200 Long Beach, California 90802-4213

SEP 0 6 2012 In response reply to: 2012/01114

Ms. Patricia Grantham Forest Supervisor Klamath National Forest

l(f'f\ . / REC~BVED ' ~ SEP102012

United States Forest Service 1711 South Main Street Yreka, California 96097-9549

Dear Ms. Grantham:

KLAMATH N.F.

On April 5, 2012, NOAA's National Marine Fisheries Service (NMFS) received your April4, 2012, letter requesting informal consultation on the Klamath National Forests' (K.NF) "Two-Bit" Vegetation Management Project (Project), pursuant to section 7(a)(2) ofthe Endangered Species Act (ESA), as amended (16 U.S.C. 1531 et seq.), and its implementing regulations at 50 CFR Section 402.

The K.NF requested concurrence that the Project may affect, but is not likely to adversely affect the federally threatened Southern Oregon/Northern California Coast (SONCC) coho salmon (Oncorhynchus kisutch; 70 FR 37160, June 28, 2005) or their designated critical habitat (64 CFR 24049; May 5, 1999). SONCC coho salmon and their critical habitat (CH) are in the Klamath River and Indian Creek, which are in the Project action area, and are therefore considered in the consultation. Habitat types occurring within the Project area include: juvenile summer and winter rearing areas, adult and juvenile migration corridors, as well as spawning habitat. The essential features ofSONCC coho salmon CH include adequate: water (volume, quality, flow, and temperature), substrate, cover/shelter (e.g .. large woody debris/LWD), riparian vegetation, space and safe passage conditions (64 FR 24049; May 5, 1999).

On June, 26, 2012, NMFS issued a letter of concurrence to the K.NF for the Project. On July 18, 2012, K.NF e-mailed NMFS with additional clarifications on the Project. Since July 18, 2012, NMFS has had several conversations with K.NF staff to better understand the Project. After receiving the new information, NMFS has re-analyzed the project, including those portions of the Project for which new information has been provided and the aspects of the project that remain unchanged by the new information. This letter supersedes NMFS' June 26, 2012, letter of concurrence for the Project and constitutes completion of informal consultation for federally threatened SONCC coho salmon and their designated CH. The Project action area has been designated as Essential Fish Habitat (EFH) of Pacific salmon pursuant to the Magnuson-Stevens Fishery Conservation and Management Act (MSA). The K.NF has determined that the Project

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may affect EFH for SONCC coho salmon, and Upper Klamath River and Trinity River Chinook salmon. This letter constitutes completion of consultation in accordance with the MSA.

Proposed Action The purpose of the Project is to allow the KNF to sustain diverse, fire-resilient ecosystems and a functioning forest and watershed that mimic historical conditions, and provide for a programmed flow of timber products. The KNF proposes to reduce fuel load (i.e., fire hazard) at the landscape level in the Indian Creek watershed and in a large portion of the Happy Camp Wildland-Urban Interface. The Project area (see enclosure two) is located within the Indian Creek, 51

h field Hydrologic Unit Code (HUC) watershed (USGS HUC #1801020901), in Siskiyou County, California, and consists of approximately 68,000 acres. The Project involves vegetation thinning and understory fuels treatments (i.e., prescribed burns) over a ten year period on approximately 9,530 acres in overgrown stands, to encourage early and mid-successional forest stands to develop into old growth stands that are less vulnerable to damaging wildland fires. Project activities will be restricted to the sediment mobilization avoidance period between May 15 and October 15 inclusive (Normal Operating Season or NOS) for the duration of the Project, to limit the potential for sediment transport and minimize in-water work. Project operations may be extended past the close of the work window on October 15 if the following conditions are met: 1) NMFS is notified ofthe pending extension prior to October 15 by the Forest Service (FS) Fish Program Manager, apprised of the current condition of the Project, given an extended weather forecast for the Project area that predicts continued dry conditions, and provided with a rationale for the time extension, 2) soil moisture content does not exceed parameters outlined in the FS wet-weather operations guidelines, 3) operations can be winterized at the end of each work day, and 4) authorization extending the operating season has not been rescinded by the KNF District Ranger (Blessing 2012).

Project water drafting will occur at approximately 21 existing sites located both outside and within SONCC coho salmon CH, the latter occurring at the 3 locations along Indian Creek and its tributaries listed below. When ambient water temperatures exceed 70° degrees Fahrenheit, no drafting will occur at the following sites: Lower Mill Creek (Project section 25), Doolittle Creek (Project section 28), and the mainstem of Indian Creek upstream of the South Fork Bridge (Project section 8). This stipulation is implemented to ensure that listed species will not be exposed to elevated temperatures of any significance as a result of decreased flows. All drafting specifications/NMFS screening criteria will be adhered to in Project sections 25, 28, and 8. In all other sections within the Project area where drafting will take place, the KNF will adhere to all NMFS drafting specifications except the screening component (see Project Activities and Effects: Water Drafting below).

Commercial thinning will occur on 1 ,940 acres of the action area, and will target those trees that exceed 10 inches diameter at breast height (dbh). Pole thinning will harvest smaller (i.e., <10" dbh) trees along roadsides and will take place on approximately 84 acres. Sanitation thinning will occur on approximately 36 acres, along less than a mile of roadside. Free thinning (i.e., removing competing trees) will occur on approximately 140 acres. Thinning to restore hardwood stands will take place on approximately 18 acres. Prescribed burning of low level vegetation outside of thinning units will occur on approximately 7,250 acres within the action area, and will occur over a ten-year period. Approximately 2.4 miles of temporary new roads

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will be constructed in 22 segments in the action area to facilitate access to areas that are not presently accessible to trucks. Approximately 4.3 miles of unclassified roads will be reopened/reconstructed in the action area, and approximately 4.1 miles of existing roads (6 segments) in the action area are scheduled to be decommissioned.

ESA Consultation Coho salmon occupy the mainstem of Indian Creek, portions of the East Fork and South Fork of Indian Creek, as well as lower Mill Creek and Doolittle Creek. Fresh water life stages of SONCC coho salmon occur in the defined action area, and include the early stages of adult migration in the mainstem of Indian Creek, juvenile rearing in the lower energy tributaries of the mainstem oflndian Creek (i.e., the East and South forks oflndian Creek, as well as in Doolittle and lower Mill Creeks), and juvenile outmigration and redistribution occurring throughout the entire system. Project activities during the NOS will take place from May 15 through October 15, placing primary spawning, incubation, and fry emergence portions of the coho salmon life history stages, which are expected to begin in November, and end in the middle of May, outside of the NOS work window. Extensions past the October 15 date may take place, but require that the four stipulations listed above in the Proposed Action section are met. If extensions to the NOS are granted, protections afforded (i.e., adherence to screening specifications, distance of Project Actions from CH, etc.) to all life stages oflisted species are sufficient to make the adverse effects occurring to either coho salmon or their CH either insignificant or discountable, as discussed below.

Thirteen miles of the mainstem of Indian Creek are regularly surveyed by KNF staff, and 12.9 miles of the mainstem have been found to contain coho salmon. There are at least 21.6 miles of CH in the Indian Creek system. The Indian Creek system is rated by the KNF staff as "high" for spawning potential, with 50 or more young of the year coho salmon having been observed in pools of the West Branch in recent surveys (Grunbaum 2006).

The eleven primary project elements described below may affect coho salmon or their CH: degradation of upslope and riparian vegetation, reduction in L WD recruitment, increased mass wasting and streambank erosion, as well as sediment transport. These primary effects may result in secondary effects, such as lowering the quality and quantity of water, reduced instream flow rates and increased temperature, loss of cover/shelter, food availability, space and safe passage conditions (64 FR 24049). KNF's analysis of such effects is contained in the "Two Bit" Project Biological Assessment! Biological Evaluation (BNBE; USDA- FS 2012). However, the Project incorporates design standards to minimize adverse effects on SONCC coho salmon and their critical habitat for both long and short term.

Primary Project Elements 1. thinning (1 ,980 acres) and other specialized silvicultural (forestry) treatments (140 acres) 2. prescribed burning (7 ,250 acres over a decade) 3. meadow enhancement (160 acres in 15 meadows) 4. road decommissioning (4.1 miles in 6 segments) 5. temporary road construction (2.4 miles in 22 segments) 6. road re-opening/reconstruction (4.3 miles) 7. landing site construction (128 existing/122 new: 60 acres total)

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8. borax stump treatments (403 acres) 9. yarding, skidding and hauling timber (throughout the project area) 10. hazard tree felling(~ 24 trees within road prism, canopy cover reduction no greater than

5% on the watershed scale); and 11. water drafting (at approximately 21 sites)

Project Activities and Effects

Thinning Treatments Thinning and other specialized silvicultural treatments (i.e., pole harvest, sanitation thinning, hardwood restoration, and free thinning to preserve desired shade intolerant species in the action area [e.g., sugar pine, Pinus lambertiana; California black oak, Quercus kelloggii; and Pacific madrone, Arbutus menziesii]) will occur on 1 ,980 acres. Thinning treatments will also remove trees that are visibly diseased (e.g., dwarf mistletoe, heart and butt rots).

Variable density tree thinning and removal treatments are intended to increase forest resilience to wildfire and to encourage the growth of larger trees that accelerate cover, shade, and L WD recruitment necessary for improved stream channel structure and sediment routing. Both commercial and non-commercial variable density thinning can result in soil disturbance and sediment delivery to adjacent streams if the thinning is too heavy, too close to a stream course or drainage, or implemented on unstable ground, inner gorges, or wetlands. Based on KNF's commitment to restrict thinning so as to be no more aggressive than previous thinning projects (Grunbaum 2012), NMFS does not expect thinning to be any greater than previous fuel reduction vegetation management projects within the KNF. The Project is designed to avoid sites, conditions, and treatments that might mobilize sediment and deposit it into salmonid habitat by restricting these activities to areas 500 feet or more away from coho salmon habitat. In addition, the FS proposes to employ appropriate erosion protection measures/devices, such as silt fencing, hay bales, straw waddles/mats, or loose straw, to prevent or minimize sediment introduction into waterways in all areas that are disturbed by the Project and have the potential to concentrate runoff(e.g., gullies, ravines, valleys, and channels) downslope ofProject activities. The combination of the setback of 500 feet and the inclusion of erosion control devices minimizes the risk of sediment transport into downslope waterways to the point of insignificance. Thus, for the reasons discussed above, thinning activities have been designed so that they will have, at most, insignificant effects on listed species and the relevant essential features of CH (i.e., water quality, vegetative cover, LWD recruitment) in the action area.

Fuel Treatments Fuel treatments will entail the reduction of vegetative and detritus fuels during and after thinning treatments to reduce excessive accumulations. The goal of fuel treatments within the riparian reserves (RR) is to maintain and restore the diversity and structure of native plant communities, and to improve riparian function for riparian-dependent and riparian-associated species. Fuels treatments in thinning units will include whole tree yarding, hand-piling and burning, burning small concentrations of debris and slash (i.e., jackpot burning), and low intensity burning under a forest canopy (i.e., underburning) and will take place on approximately 2,120 acres in the action area. Fuel treatments in the RRs will maintain consistency with the Aquatic Conservation Strategy goals listed in Appendix G of the BA, and will comply with the Project Design

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Standards as described in the Klamath National Forest: Pre-commercial Thin and Release/Fuels Hazard Reduction document (KNF 2001). The Projects bum plans specify that underbuming in stream course RRs be kept at low intensities to insure that adequate soil cover is retained, that the soil is not scorched, and the canopy that may be scorched is limited to the removal of fuels from the "fire-ladder" (due to its size, this small amount of scorching is not expected to result in more than an insignificant reduction to the canopy). The amount of canopy that might become scorched will be minimal, and as such, any canopy reduction will have insignificant effects on coho salmon or their CH.

Approximately two miles of the perimeter of prescribed burning outside of thinning units is adjacent to coho salmon and Chinook salmon habitat. Controlled bums in RRs will commence away from waterways and be allowed to "back down" to the riparian areas. As explained in the BA and taking into account the application of the Project Design Standards described above, and the results of past projects using the same methodology, crews on-site are expected to maintain control of bums at all times, and will cease burning activities if any condition (e.g., excessive windspeed) threatens to jeopardize control of the bum. These underbums are specifically designed to result in low intensity bums in RRs so that substrate integrity is retained, and the potential for erosion is minimized to the point where it is extremely unlikely to occur. Project fuels treatments may, therefore, result in only insignificant effects on turbidity, substrate, and peak/base flows. As the FS implements prescribed fires, they will use the methodology described above, the underbuming is expected to consume small understory vegetation and reduce excessive ground fuel, but not be so hot that soil is scorched, or overstory (i.e., canopy) is scorched beyond beneficial reduction/removal of the "fire-ladder.

By reducing understory stocks, the fuels treatments will serve to improve the health of residual vegetation cover in the RR. The low intensity nature of these prescribed riparian bums diminishes the potential for conflagrations that would likely occur if the forest were left in an unmanaged state. Such fires would have the potential to produce highly negative effects on listed species in local waterways. The prescribed bums will be staggered over space and time (i.e., occurring in different areas spaced out over a decade), which renders the combined effect insignificant. Therefore, these treatments are likely to have an insignificant adverse effect in the short-term, and a long-term beneficial effect on coho salmon and the relevant essential features ofCH (i.e., water quality, vegetative cover, LWD recruitment) in the action area.

Meadow Enhancement Meadows in the Project area are being encroached by conifers due to the long interval since the last wildfires burned in these areas. Meadow restoration will entail removing these conifers and will occur on approximately 160 acres in 15 meadows in order to maintain biodiversity and restore meadow hydrology and function. Meadow restoration will not encroach any closer than 3,700 feet from salmonid habitat. This activity will have no effect on listed coho salmon or their CH.

Road Construction/Reopening/Decommissioning Road construction/decommissioning/reopening involves the 1) removal of stream crossings and 2) reopening of unclassified roads, which in tum have the potential to introduce sediment into waterways, and may cause short term negative effects locally, such as increased turbidity,

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decreased water quality, and sedimentation of the stream bottom downstream of Project activities. The FS will employ similar erosion protection measures/devices as those listed in the thinning activities section above, such as silt fencing, hay bales, straw waddles/mats, or loose straw in all areas downslope of road construction activities to prevent/minimize the introduction of sediment into waterways. All of these potential impacts diminish with distance downstream ofProject activities. Vegetation/tree removal in and near the proposed roadways has the potential to result in elevated stream temperatures; this related aspect of road construction/reopening/ decommissioning is addressed in the section on hazard tree removal.

A. Stream Crossing Removal

Road decommissioning will require the removal of seven intermittent stream crossings, and two perennial stream crossings at tributaries to Sutcliffe and Doolittle creeks. All of the intermittent stream crossings are located more than a mile upstream of listed coho salmon CH, and all of them will be in a dewatered state. Additionally, coho salmon have not been observed at any time of the year within a mile of these sites. Work involving the two perennial stream crossings will only occur between July and September. In this time period, these two streams experience extremely low flow{< 1 cubic foot/minute) under normal hydrologic conditions, rendering coho salmon presence extremely unlikely. As such, Project activities will likely produce turbidity in waters local to excavation but in a location where fish will not be present. Effects downstream will be discountable as extremely low flows will ensure that even the finest particulate matter will settle out onto the stream bottom well before reaching SONCC and their designated CH located more than a mile downstream.

Slash (i.e., limbs taken from the timber harvested on site) that is a half-inch to six-inches in diameter, and from two to six feet in length, will be placed into the steam channel at the excavation site and for at least 50 feet downstream, after all Project cross-stream skidding has been completed. The potential amount of sediment transported downstream will be limited to inconsequential volumes, generally less than one half of a cubic yard (USDA-FS 2003, 2004). The addition of slash to the streambed is designed to trap much of the remaining substrate disturbed during excavation at the site. The long-term benefits of decommissioning and removing these existing crossings, in combination with the insignificant short-term negative effects will impart an overall improvement to the state of the local benthos. The removal of these structures will enhance rearing habitat through bank stabilization, providing the conditions that juvenile coho salmon favor in tributaries. The beneficial effects modeled estimate an annual reduction of 14 cubic yards of sediment introduced into the waterways, and an additional reduction of 2,079 cubic yards of sediment from mass wasting over the next decade. These benefits derive from restoration activities such as improving hill slope hydrology, the removal of inboard ditches and cross drain culverts, as well as road stabilization.

Any post excavation sediment transport resulting from stream crossing removal will also be short-term, occurring during winter storm events for one- two years following excavation, depending on stream flow magnitude. These effects will be proximal to the excavation, only detectable at the site scale (Madej 2001, Foltz et al. 2008) and will not approach CH downstream. They will include stream channel incision and slope erosion at, and immediately downstream from the excavation site. Winter storm events will produce increased turbidity

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locally, and increased sedimentation downstream from the excavation. Monitoring from similar actions within the Klamath National Forest (USDA-FS 2003, 2004) have shown that the short­term effects of this activity are insignificant (i.e., an average of 0.34 cubic yards of sediment was displaced for each of the 80 locations monitored) to the fitness of individual coho salmon and critical habitat (particularly when the lifecycle of the species is taken into account), and that the long term effects are likely to be beneficial as the final state of the waterway will more closely approximate an unaltered, natural condition.

B. Reopening Unclassified Roads

Reopening unclassified roads will entail removing saplings, small trees and undergrowth that have emerged since the road was last used, and reshaping the road as necessary. This may involve repairing areas where erosion has occurred since last use of the road. As with other construction activities that disturb the substrate, the FS will make use of appropriate erosion control devices. Unclassified roads that are scheduled to be reopened are located more than 500 feet away from CH. Streams adjacent to the unclassified roads that will be re-opened will be protected by: (1) correcting existing road-drainage problems before the road is used in the Two­Bit project, (2) using appropriate erosion-control methods during re-opening and use, and (3) post-project hydrologic decommissioning of the roads using the same erosion-control measures that will be used in the decommissioning of classified roads in the Sutcliffe and Doolittle sub­watersheds, as appropriate to minimize the amount of sediment introduced by project actions to very low levels at which no reduction in coho salmon fitness might be expected. Canopy cover that might be lost in implementing the action will only involve the removal of saplings and underbrush, and will have no impact water temperatures (see Hazard Tree Removal section below), and erosion control measures and devices used will provide a buffer to minimize sediment impacts. As the scope and methods related to the reopening of classified roads are similar to other past, projects that have proven to have only insignificant effects, and taking into account the buffer and erosion control measures provided, the sediment, turbidity, and water quality impacts related to the reopening of unclassified roads are expected to be insignificant with regard to coho salmon and their CH. Accordingly and as further explained in "Hazard Tree Removal" , any construction activities involved in reopening unclassified roads (e.g., vegetation removal, grading, compacting) are not likely to adversely affect coho salmon or their CH.

Borax Treatments The borax compound (Sporax®) will be applied to freshly-cut white and Shasta red fir stumps > 14 inches in diameter, at a ratio of approximately one pound of compound per 50 square feet of stump surface, to inhibit the spread of Heterobasidion annosum ("annosus") root disease. This treatment will also be implemented on other conifer species in thinning areas where Heterobasidion root disease already exists. This treatment is common practice and will be employed on approximately 403 acres within the Project area. No borax treatments will be used within 500 feet of waterways holding coho or Chinook salmon, steelhead or rainbow trout. No effluent containing boron products will be discharged into any waterbody. Therefore, these treatments' effects on coho salmon and their CH are discountable.

Hazard Tree Removal Felling of hazard trees will be minimal and when performed in RR, will not reduce canopy cover

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below 80% at the reach scale, or below 95% at the watershed scale. Maintaining 80% canopy cover at the reach scale, and 95% at the watershed scale will continue to provide sufficient shade to prevent thermal loading of affected streams and retain adequate thermal refugia for listed salmonids. The limited number of trees qualifying as hazard trees and selected for removal will not reduce shade cover appreciably and will have, at most, insignificant effects with regard to shade cover. Thus, with a maximum of 20% cover loss at the reach scale, and 5% at the watershed scale, there is little likelihood that thermal loading from increased exposure to sunlight would produce significant increases in water temperatures locally or downstream of, hazard trees removed. Therefore, hazard tree removal that is limited to 20% at the reach scale, and 5% at the watershed scale is not likely to adversely affected listed species or their CH. This insignificant reduction of canopy cover will have an insignificant effect on water temperatures at, and downstream of the removal site. Hazard trees that are felled on site will remain, except those that fall within a road prism which are expected to be <24 trees. Hazard tree felling is expected to produce a net increase in L WD recruitment in the Project area. This will provide a benefit to the local habitat by increasing instream complexity.

Water Drafting Water drafting operations can mobilize suspended sediment to downstream aquatic habitat. Suspended sediment increases turbidity, exposing juvenile fish to gill damage and reduced oxygen uptake, and/or reduced vision and compromised feeding effectiveness. Deposition of suspended sediment can fill interstices of stream bottom substrate, deprive incubating eggs of dissolved oxygen, and result in their asphyxiation. Although drafting operations can mobilize sediment when the intake is first installed, the intake is within inches of the water surface and well away from the substrate, and is therefore unlikely to produce the amount of suspended sediment which could imperil coho salmon eggs during drafting operations.

With the exception of screen use at Project sections 8, 25, and 28, all NOAA Fisheries Water Drafting Specifications (2001) and Project Design Features (PDF) will be followed, limiting the rate(~ 350 gpm), timing (beginning 1 hour after sunrise- ending 1 hour before sunset), and the duration(~ 30 minutes) of water withdrawals, so that reductions in flow volume and increases in stream temperature will be insignificant on site and discountable downstream. Additional restrictions include limiting drafting rates to 10 percent of the total flow. Drafting in Project sections 8, 25, and 28 must utilize NMFS approved "fish friendly" screens, oriented according to specifications (i.e., with the screen face perpendicular to flow direction), and adhering to approach and sweeping velocities stipulated. Drafting also must not result in obvious draw­down of either upstream or downstream pools. A record of drafting activities must be kept in a logbook with serially numbered pages that annotates the operators name, date, time, pump rate, filling time, screen cleaned (YIN), screen condition, and comments as appropriate. Coho salmon may be present in the East Fork of Indian Creek, but drafting will not occur at any time on the East Fork of Indian Creek.

Based on the project as described and NMFS' observations of similar projects, no measurable increase in turbidity is expected beyond the immediate area where drafting occurs, as turbidity associated with drafting will dissipate quickly to ambient conditions. The effects of drafting at the intake site are expected to be momentary, infrequent, and localized; furthermore, based on the methods used, we expect that the amount of sediment disturbed will be insignificant and that

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these small, ephemeral plumes of suspended sediment that coho salmon might be exposed to will not cause gill damage, reduced oxygen uptake, reduced vision, filling of interstitial spaces, or compromised feeding.

The screens in sections 8, 25, and 28 will prevent the entrainment and impingement of coho salmon in those sections. The presence of coho salmon outside of those sections is extremely unlikely; therefore, any effects related to the lack of screening outside of those areas is discountable.

Coho salmon exposed to water drafting activities are expected to display avoidance behavior consistent with responses to general noise and vibrations caused by human activities along stream channels. NMFS has visited the potential water drafting sites, and noted that there is "in place and in kind" accessible habitat of comparable size and quality that coho salmon could use during drafting activities. NMFS therefore anticipates that coho salmon avoiding water drafting activities are not likely to result in reduced feeding success, or increased exposure to predation. The totality of the Project requirements has the effect of minimizing potential hazards to coho salmon and their CH to render them insignificant.

Yarding and Skidding Skidding involves dragging felled timber from its original growth site, to areas that have roadways where the timber may be hauled away by truck. A small percentage of timber will be transported via skyline and mobile yarders. Skylines and mobile yarders will be used to move timber from remote areas to staging areas where the harvested wood may be moved via skidder, or loaded directly onto trucks. Full suspension cable yarding will be employed if it becomes necessary to move timber across stream channels, and riparian zones within 1 0 feet of streams. Single-end suspension cable yarding would be used where necessary in the remainder of the surrounding stream course. Skidding will not occur over any bodies of water. Terrestrial based yarding and skidding activities will occur no closer than 500 feet from coho salmon CH, areas where SONCC coho salmon might be found, and from coho and Chinook salmon EFH. The FS will employ the same erosion control BMPs listed in the "Thinning Treatments" section above. Based on the erosion control measures utilized and the distance between terrestrial yarding and skidding activities from salmon habitat, this activity is expected to have insignificant effects on listed coho and their CH.

Hauling of Timber Approximately 144 miles, of the 316 miles of roadways within the Project are will be used for Project activities. About ten miles of the 144 will be adjacent to (i.e., within 100 feet) salmon and/or steelhead/rainbow trout habitat. Eight ofthe ten miles of roadway that is adjacent to salmon/trout habitat is on paved, two-lane County roads that are travelled regularly. Existing classified and unclassified roads that will be used for log-hauling pass intermittently through stream course RRs, and occasionally over geologic RRs. Per a telephone conversation with Jon Grunbaum of the USFS/KNF, the fleet used to haul timber will consist of 5-7 trucks/day, each truck carrying up to 2 loads (maximum) per day, with trucks spaced at least twenty minutes apart (based on loading cycle time).

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Depending on project specifics, noise, vibration, the casting of shadows and dust from timber hauling may affect fish. All of the unclassified roads that will be reopened are set back at least 500 feet from CH (Grunbaum 2012). There are a limited number of stream crossings that bisect intermittent or ephemeral stream courses. All exposure of listed species to the effects of log hauling will be insignificant because that exposure to truck presence on roads adjacent to salmonid habitat will be intermittent (n ~ 14 per day) and fleeting (t <10 second duration). For all roads, except those that cross streams, the buffer between the roads and the streams provides another dimension of protection to SONCC coho salmon and their CH. All Project haul routes will receive dust abatement treatments which will ensure worker safety, minimize dust introduction into neighboring residences, and reduce airborne dust delivery to streams. Based on annual monitoring of BMP erosion control performance measure effectiveness for soils and water quality (USDA-FS 2003, 2004) Project timber haul is expected to result in, at most, insignificant increases in stream turbidity, and peak/base flows, both at the Project site and 0.15 mile down slope to the closest SONCC coho salmon critical habitat.

Landing Site Constructionffreatments There are 128 existing landing sites, and 122 new sites will be constructed; constituting 60 acres in total. Depending on project methodology and site location, landing site construction and treatments may create sediment related impacts. Landings are among the most disturbed sites from logging activities. These sites have significantly lower site productivity due to compaction and nutrient loss if they are not remediated after the Projects completion. All landing construction and reconstruction sites will be located more than 500 feet from salmonid habitat. As stated in BMP 1.12 "the objective is to locate new landings or reuse old landings in such a way as to avoid watershed impacts and associated water quality degradation." To the extent possible, existing sites would be used in lieu of constructing new landings. Existing landing sites within 30 feet of the slope break to a stream channel or inner gorge will not be used. Landing sites already existing in RRs will not be enlarged and new sites will not be constructed in RRs. Site selection for both existing and proposed landings would consider potential excavation and erosion impacts, and chose those with the smallest footprint and erosion potential.

BMPs 1.15 and 1.16 expand on these practices. Landings will be shaped to direct runoff away from watercourses and into holding pools or other suitable drainage. Erosion control devices (e.g., silt fencing, straw bales/wattles, rock anchoring, slash) will be utilized downslope of disturbed substrate at landing sites to prevent sediment transport into watercourses. Slash will be maintained throughout the duration of the Project. Following Project completion, all landings will be hydrologically decommissioned at the end of use in the Two-Bit Project. Based on these measures, any effects from the use or construction of landing sites are expected to be discountable.

ESA Determination The BMP measures listed in the addendum to the BA/BE, Appendix A (see enclosure 1) are designed to minimize adverse impacts to the riverine ecosystem and have been incorporated into the proposed Project work plan. Based on our review of the proposed Project and the best scientific and commercial information available, the use of BMPs that have protected and enhanced stream habitat conditions in similar projects and environmental conditions, and the extended period of implementation (i.e., 10 years) dispersed over the 51

h field watershed, NMFS

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concurs with the KNF's determination that the Project may affect, but is not likely to adversely affect federally threatened SONCC coho salmon or their designated CH. The potential for adverse effects to coho salmon or their designated CH are insignificant or discountable.

This concludes informal consultation for the proposed action. Reinitiation of consultation is required where discretionary Federal agency involvement or control over the action has been retained or is authorized by law and if: 1) new information reveals effects of the action that may affect listed species or CHin a manner or to an extent not previously considered, 2) the action is subsequently modified in a manner that causes an effect to the listed species or CH that was not considered, or 3) a new species is listed orCHis designated that may be affected by the action.

Essential Fish Habitat Effects Determination

The Pacific Fishery Management Council has delineated EFH for Pacific Coast salmon, which includes the action area of the Project. The Project area is located within an area identified as EFH for various life stages of coho salmon and Chinook salmon managed under the Pacific Coast Salmon Fishery Management Plan (FMP) under the MSA. NMFS has evaluated the Project for potential adverse effects to EFH pursuant to Section 305(b)(2) ofthe MSA. Under the EFH implementing regulations [50 C.F.R. 600.81 O(a)], the term "adverse effect" is defined as any impact that reduces quality and/or quantity ofEFH and may include direct or indirect physical, chemical, or biological alterations of the waters or substrate and loss of, or injury to, benthic organisms, prey species and their habitat, and other ecosystem components, if such modifications reduce quantity and/or quality of EFH.

NMFS has determined that the Project would adversely affect EFH for coho salmon or Chinook salmon. However, due to the resource protection measures and BMPs incorporated into the Project which will avoid, minimize, mitigate or otherwise offset adverse effects to EFH, NMFS has no additional conservation recommendations to provide. This concludes EFH consultation for the Project. Pursuant to 50 CFR 600.920(1), the KNF must reinitiate EFH consultation if it substantially revises its plans for the action in a manner that may adversely affect EFH or if new information becomes available that affects the basis for NMFS EFH Conservation Recommendations.

If you have any questions regarding this consultation, please contact Stephen Hillyer at (541) 885-2504, or via e-mail at stephen.hillyer@noaa.gov.

Sincerely,

fo~~zy~ Rodney R. Mcinnis Regional Administrator

cc: Jon Grunbaum, KNF, Happy Camp, CA Copy to Administrative File: 151422SWR2011AR00077

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References Cited:

Blessing, D. 2012. Personal communication. Natural Resource Officer. Happy Camp Ranger District, Klamath National Forest. Happy Camp, CA.

Foltz, R., N. Copeland and W. Elliot. 2009. Reopening abandoned forest roads in northern Idaho, USA: Quantification of runoff, sediment concentration, infiltration, and interrill [sic] erosion parameters. Journal of Environmental Management 90: 2542-2550.

Grunbaum, J. 2006. Personal communication. Fish biologist. Happy Camp Ranger District, Klamath National Forest. Happy Camp, CA.

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